Updated management performance audit procedures for batteries, EEE and HSP now posted
RPRA has published updated Management Performance Audit procedures for batteries, ITT/AV and lighting (EEE), and hazardous and special products (HSP). The following procedures have been updated to include the finalized performance audit procedure:
- Batteries Registry Procedure – Verification and Audit
- EEE Verification and Audit Procedure
- Hazardous and Special Products Verification and Audit Procedure
The management performance audit procedures are intended to be used by PROs reporting on behalf of producer clients, for producers that report on their own activities and their respective third-party auditors, to meet their performance audit reporting requirements.
Most producers have retained the services of a PRO to complete their reporting on their behalf. However, it remains the responsibility of a producer to ensure their reports are submitted by the deadline to avoid compliance action.
Consultation outcomes
RPRA consulted on the development of the procedures in 2023.
Finalizing the procedures and formally closing the consultation took longer than anticipated because RPRA needed to account for significant regulatory amendments made to all applicable regulations in late 2024 and to review and respond to substantive consultation feedback.
RPRA considered all feedback received when finalizing the procedures. In response to that feedback, RPRA made changes to the final procedures to support registrants in successfully completing the performance audit. Key changes include:
- elevating audit integrity by transitioning from CSRS 4400-level procedures to the rigorous CSAE 3000 reasonable assurance standard
- consolidating and clarifying program-specific reporting definitions
- continuing to provide detailed suggested audit procedures for CSAE 3000 engagement
Visit the consultation webpage to learn more about the consultation process and read the consultation report summarizing stakeholder feedback received.
Next steps for producers and their PROs
The deadline for the first performance audit reports will be determined in consultation with PROs. Over the coming weeks, RPRA will connect with PROs to align on the proposed implementation timing and communicate the finalized timeline to all impacted parties.
RPRA understands there may be data limitations when reporting on past performance years. RPRA will work with PROs and their auditors to help meet regulatory requirements and deadlines. RPRA encourages any questions to be directed to the Compliance and Registry Team [email protected].